British Crop Production Council joins food and farming organisations' concerns over EU endocrine disruptor regulatory criteria

Organisations involved in the UK food and farming sectors, including the British Crop Production Council (BCPC), have expressed great concern at the European Commission's proposed criteria for endocrine disruptors (EDs) within the Plant Protection Products Regulation.

BCPC's Dr Colin Ruscoe
BCPC's Dr Colin Ruscoe

A joint letter to George Eustice MP, Minister of State for Agriculture, Fisheries and Food at Defra, sent last monht, urges him to take a robust position.

"The signatories are particularly concerned that the proposed criteria will lead to the withdrawal from the market of important plant protection products, which will adversely crop production and so UK competitiveness in agriculture, food and trade," said Dr. Colin Ruscoe, president of BCPC.

The current ED criteria are based on the World Health Organisation International Programme on Chemical Safety (WHO/IPCS) definition, which is unsuitable on its own to support regulatory decision-making, argues Ruscoe.

"They fail to be take into account all elements of hazard characterisation, including potency, severity and duration of effect, and elimination, all critical to the overall risk assessment needed to determine any real danger to human health and the environment.

"Until the UK formally exits the EU, we remain subject to EU law and regulations, and under the government’s Repeal Bill proposals, for some time afterwards. We have therefore strongly urged the Minister to continue to promote use of science-based risk assessment as the basis of EU regulation to support modern, productive and sustainable agriculture, and to challenge hard the Commission’s flawed proposals on EDs," said Dr. Ruscoe.

Furthermore, the Commission is now proposing two acts, one covering the proposed criteria, and a new one, to amend the current negligible risk derogation. The derogation is crucial to avoiding negative impacts on trade, since it allows MRLs based on risk assessment.

"This raises concern that the Commission is creating a focus on the derogation to get even this opportunity curtailed," he warned.

Text of letter to George Eustice signed by: BCPC, Agricultural Industries Confederation, Association of Independent Crop Consultants, Amenity Forum, British Beet Research Organistion, British Growers Association, British Society of Plant Breeders, Country Land and Business Association, Crop Protection Association, Fresh Produce Consortium, National Farmers' Union, Velcourt, Food and Drink Federation, National Association of Agricultural Contractors, National Association of British and Irish Flour Millers, Ulster Farmers' Union.

Dear Minister
We are writing to you as a range of organisations involved in the UK food and farming sectors, to
express our concerns at the European Commission’s current proposed criteria for endocrine
disruptors as required in the Plant Protection Products Regulation, and to urge the UK Government to
take a robust position to ensure the final criteria do not inflict serious damage on domestic agricultural
and horticultural production and the wider food industry. We are particularly concerned that the
current criteria will lead to the withdrawal from the market of a significant number of important plant
protection products, which will have an adverse impact on crop production in the UK, and on those
sectors, both downstream and upstream, which rely on profitable and competitive agricultural and
horticultural industries.
In order to strike the right balance between protection of human health and the environment on one
hand and socio-economic impact on the other, it is essential that the final criteria identify substances
that are of genuine concern. In our view, this balance has not been struck as the current criteria are
based almost solely on the World Health Organisation International Programme on Chemical Safety
(WHO/IPCS) definition, which by itself does not constitute criteria suitable to support regulatory
decision making. The proposed criteria fail to allow all available and relevant scientific evidence,
including potency, to be taken into account when evaluating a substance for its endocrine-disrupting
properties. Based on the Commission’s impact assessment, the proposed criteria will have a
disproportionately negative impact on the availability of plant protection products for farmers and on
sectorial competitiveness, agriculture, and trade. Given that all options under consideration, including
those comprising elements such as potency, were found to offer the same high level of protection for
human health and the environment, it is difficult to understand why the Commission has put forward
these criteria.
In our view, endocrine disruptors can and must be regulated like most other substances of potential
concern and be subject to risk assessment which considers both hazard and exposure. Although the
Commission has proposed derogations for substances triggering the hazard based approval criteria
by considering some elements of risk and exposure, introducing these elements by derogation
increases uncertainty in the regulatory framework and signals a fundamental flaw in the basic
regulation.
If the endocrine disruptor criteria are to be fit for purpose, all elements of hazard characterisation
(and not just hazard identification) must be built into them, including potency, severity, and lead
toxicity. Hazard characterisation is an essential step in the overall risk assessment of a substance
and these elements are essential to ensure that regulators have the necessary tools to clearly
distinguish between those substances which pose a real danger to human health and the
environment and those that do not.
As proposed, these criteria will result in farmers and growers losing safe and essential tools that help
them to produce the food that we all take for granted. A 2014 report by the Agriculture and
Horticulture Development Board (AHDB) estimates an impact of at least £905m (10%) on industry
farm-gate value. Also, as highlighted in the Commission’s impact assessment, the loss of crop
protection products increases the risk of pests, weeds, and diseases developing resistance to the
products that remain. This could further impair the competitiveness of UK farming and horticulture,
while potentially having dangerous consequences for food safety, for example, by hampering
farmers’ ability to prevent harmful mycotoxins from entering the food chain. Additional impacts on
competitiveness and public safety can be expected if the amenity sector loses access to key tools for
weed and pest control, such as those required to maintain the safe running of railways.
We think it would be in the best interest of the UK to see the criteria changed to include elements of
hazard characterisation. In order to allow all available and relevant scientific evidence to be taken into
account when evaluating crop protection products for potential endocrine-disrupting properties, these
should include not only potency, but also severity, reversibility and lead toxicity.
Although there is currently uncertainty about the future regulatory system of the UK following Brexit,
until the UK formally exits the EU we will remain subject to EU law and regulations, and under the
government’s Repeal Bill proposals for some time afterwards, at least in the short to medium term.
Consequently, we strongly urge the UK to continue to promote use of science-based risk assessment
as the basis of regulation to support modern, productive and sustainable agriculture in Europe, and to
strongly challenge the Commission’s current proposals on endocrine disruptors on the grounds set
out in this letter.


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